HMDA Reporting Rates: Gender|Race|Ethnicity

Mortgage TrueView HMDA Insight Dashboards[1] show that the rate at which net adjusted applications[2] include applicant gender, race, and ethnicity rates vary in a given MSA compared to the overall rate of 85.60% (Chart 1)

Gender, race, and ethnicity reporting rates and related variances show that it is essential to understand the MSA- and lender-specific gender, race, and ethnicity reporting rates to properly evaluate a lender’s lending profile on a direct and comparative basis.

As expected, the gender, race, and ethnicity reporting rate is the highest for approved loans and the lowest for incomplete loans.

The gender, race, and ethnicity reporting rates for denied and withdrawn rates are comparable, raising the issue of whether or not a written request for withdrawal was received before a credit decision was made.

The gender, race, and ethnicity reporting rates for incomplete and withdrawn applications highlights the challenge in evaluating a lender’s fair lending profile for these applications.

The evaluation of a lender’s fair lending profile is more problematic – and perhaps impossible – in MSAs/MDs where the overall rate of gender, race, and ethnicity reporting is below a standard threshold.

Lenders with gender, race, and ethnicity reporting rates below the average for an MSA are likely to attract the attention of regulators. Perhaps more important, lenders lack relevant demographic information to grow their business.

Lenders with gender, race, and ethnicity reporting rates above the average for an MSA face a risk/reward paradox – higher gender, race, and ethnicity reporting rates result in greater scrutiny of their lending while the lending profile for lenders with lower gender, race, and ethnicity reporting rates is less certain therefore lowering the likelihood that the heightened scrutiny will yield a favorable reaction from regulators and other stakeholders.

* *

Our next HMDA Insight will provide further insight in gender, race, and ethnicity reporting by presenting instances of data issues not detected through HMDA validity and quality edit checks performed by the Federal Financial Institutions Examination Council at the time lenders submit their data.

* * *

“It is a capital mistake to theorize before one has data. Insensibly one begins to twist facts to suit theories, instead of theories to suit facts.”― The Adventures of Sherlock Holmes, A Scandal in Bohemia

* * * *

[1] Mortgage TrueView dashboards can be accessed by 2015 HMDA Survey participants using their complementary access credentials. Non-participants may obtain credentials by sending a request to hmda@mortgagetrueview.com.